On April 25, 2002, the General Assembly passed House Bills 918 and 919, which provided for local homestead exemptions for Dade County, subject to the approval of Dade County voters. House Bill 918 established a homestead exemption from certain Dade County ad valorem taxes for county purposes in an amount equal to the amount by which a residential property’s current year assessed value exceeds the base year assessed value. House Bill 919 established a similar homestead exemption from certain Dade County School District taxes for educational purposes. The base year under the bills “is the taxable year immediately preceding the taxable year in which the homestead exemption is first granted to the most recent owner of the homestead.” The bills therefore generally establish acquisition value tax exemptions. The exemptions are available to homeowners only, and they apply only to a taxpayer’s primary residence and not more than three contiguous acres of land immediately surrounding the residence. The exemptions do not apply to taxes assessed on “improvements to the homestead” or to land that is added to the homestead after July 1 of the base year. Dade County voters approved the homestead exemptions on November 5, 2002. Appellant Rex Blevins owns land in Dade County but not a home that qualifies for the exemptions. He brought this action, challenging the constitutionality of the homestead exemption bills on several grounds. The trial court ruled against Blevins’s claims, and he appealed. We now affirm.
1. Blevins contends that the tax exemptions violate the Uniformity Clause of the Georgia Constitution, which provides that “all taxation shall be uniform upon the same class of subjects within the territorial limits of the authority levying the tax.” Ga. Const. of 1983, Art. VII, Sec. I, Para. III a. In addition, Paragraph III b provides that, with limited exceptions not applicable here, “the classes of subjects for the taxation of property shall consist of tangible property and one or more classes of intangible personal property.”
